Epic webinar compliance

COMPLIANCE OUTLOOK FOR HEALTH
AND WELFARE PLAN SPONSORS
Where We’ve Been and What’s Ahead in 2016
November 19, 2015

2© EPIC Insurance Brokers & Consultants
TODAY’S PRESENTER
KRIS BEALE
Senior Compliance Consultant | EPIC Employee Benefits
Kris provides compliance support for private and public
employers on a wide variety of employee benefits matters
including the Affordable Care Act, Internal Revenue Code,
ERISA, COBRA, HIPAA, municipal ordinances, plan
documentation, DOL audits and more. Kris has over 17 years
of experience in employee benefits, including HIPAA privacy
and security consulting.

AGENDA
 Where we’ve been in 2015
– Summary of regulatory and legal developments
 What’s ahead in 2016
– Federal benefit limits
– W-2 reporting of health plan costs
– PCORI fees
– Transitional Reinsurance Program fees
– Employer Shared Responsibility rules
– Employer health coverage reporting
 Beyond 2016
– Cadillac tax?
 Recommended steps for employers
 Additional resources

4© EPIC Insurance Brokers & Consultants 44
WHERE WE’VE BEEN IN 2015

SUMMARY OF 2015 REGULATORY & LEGAL
DEVELOPMENTS
JAN HIPAA certificates of creditable coverage eliminated
FEB
IRS releases final instructions and forms for ACA health coverage
reporting; announces 2016 group health plan cost-sharing limits and
clarifies self-only limit applies to each covered person (under self-
only or family coverage)
APRIL
IRS issues additional guidance about premium reimbursement
arrangements (“employer payment plans”)
MAY
Out-of-pocket maximum under HSA-compatible HDHP same for all
covered persons in 2016; guidance clarifies preventive services
includes contraceptives, cancer screening and more for plan years
(PY) starting on or after 7/10/15
JUNE Supreme Court upholds ACA subsidies in all states; legalizes same-sex
marriage nationwide; SBC delivery rules updated, simplified

SUMMARY OF 2015 REGULATORY & LEGAL
DEVELOPMENTS
JULY
IRS issues Notice 2015-52, continues process of implementing
Cadillac tax, invites public comments
AUG IRS launches “AIR” system for e-filing of Forms 1094/1095
OCT
ACA small group market definition repealed; IRS announces 2016
benefit limits; Surface Transportation and Veterans Health Care
Choice Improvement Act of 2015 Act includes benefits-related
changes related to veterans and Form 5500 filing extensions; ACA
auto-enrollment repealed
NOV
ACA guidance on preventive services, wellness, mental health parity;
EEOC issues proposed regulations related to GINA and workplace
wellness programs

WHAT’S AHEAD IN 2016

2016 BENEFIT PLAN LIMITS
 Health savings accounts (HSAs)
– Maximum contribution: $3,350 self‐only/$6,750 family
 High deductible health plans (HDHPs)*
– Minimum deductible: $1,300 self‐only/$2,600 family (no change)
– OOP maximum: $6,550 self-only/$13,100 family
– “Self-only” limit applies to OOP maximum even if enrolled in family
coverage
 OOP maximum for essential health benefits (non-grandfathered plans)*
─ $6,850 self-only/$13,700 family
─ “Self-only” limit applies to OOP maximum even if enrolled in family
coverage
 Qualified Transportation Benefits
– Parking: $255/month
– Transit pass/commuter vehicle: $130/month (no change)
* Note: State laws may set different limits for insured plans and HMOs

SURFACE TRANSPORTATION ACT
Surface Transportation & Veterans Health Care Choice Improvement Act
 Signed into law September 2015; several provisions may affect employers
Military veterans and ALE calculation
 Allows employers to exclude veterans receiving medical coverage under
certain health care programs provided by the Department of Veteran
Affairs (VA) from determination of the employer’s ALE status
 May apply retroactively for 2014 (which determines employer’s ALE
status for 2015)

SURFACE TRANSPORTATION ACT (CONT.)
Health Savings Accounts and Veterans
 Starting in 2016, individuals receiving VA benefits for hospital or medical
services for a service-connected disability will not fail to be eligible to
receive or make contributions to an HSA
 Individuals with other conditions remain ineligible to make or receive HSA
contributions if they received VA-administered care in preceding three
months (other than certain preventive services)
Form 5500 extension deadline
 For PYs starting on or after January 1, 2016, the automatic extension of
time to file Form 5500 is lengthened to 3½ months, up from 2 ½ months
─ Example: PY ending December 31, 2016 may obtain an extension to file
by November 15, 2017 to file the Form 5500 (instead of October 15)

W-2 REPORTING OF HEALTH PLAN COSTS
 W-2 reporting
- Employers (insured or self-funded) must report the value of group
health coverage on employee’s W-2 (Box 12, Code DD)
- Reporting is informational only; no tax consequences
– Employers who filed fewer than 250 W-2s for 2014 are exempt from the
health coverage informational reporting requirement for 2015.

PCORI FEE
 Patient-Centered Outcomes Research Institute (PCORI) Fee
- Applies to all group health plans, unless primarily “excepted benefits”
- Carrier pays for insured plans; plan sponsor pays for self-funded plans
o If employer sponsors an insured medical plan integrated with a self-funded plan,
employer pays fee for self-funded plan and insurer pays fee for insured plan (e.g. HRA
integrated with insured major medical plan); if two or more self-funded coverages are
integrated by same employer (e.g., HRA and prescription drug plan integrated with major
medical plan), the employer pays the fee once with respect to the entire integrated self-
funded plan
- Applies annually for each plan year ending after September 30, 2012 and before
October 1, 2019
- Fee is reported and paid once a year, by July 31 following the calendar year in
which the plan year ends
- $2.08 per covered life (for plan year ending between 10/1/2014 and 9/30/2015)
or $2.17 (for plan year ending between 10/1/2015 and 9/30/2016)
- Example: For plan years ending between October 1, 2015 and December 31, 2015,
$2.17 per covered life fee is due by July 31, 2016
- Report and pay fee using Form 720 (Quarterly Federal Excise Tax Return)

TRANSITIONAL REINSURANCE PROGRAM (TRP) FEE
 Annual fee applies to health plan coverage that provides “minimum
value” (other than “excepted benefits,” integrated HRAs, health FSAs, or
carve-out drug plans)
 Carrier pays for insured plans; plan sponsor pays for self-funded plans
 Temporary program – 2014 to 2016
─ 2014 contribution = $63 per covered life
 Employer schedules payment due dates when calendar year enrollment
count is reported to CMS
– Enrollment count reports for 2015 due November 16, 2015
– 2 payment options for 2015 contributions:
o Pay in full ($44.00) by January 15, 2016
o Pay in 2 parts: $33.00 by January 15, 2016 and $11.00 by November
15, 2016

EMPLOYER SHARED
RESPONSIBILTY RULES
(‟PLAY or PAY”)

EMPLOYER SHARED RESPONSIBILITY RULES
Background
An ‟applicable large employer” (ALE) that fails to offer
minimum essential coverage (‟MEC”) to full-time (FT)
employees and their children (to age 26) may be subject to a
penalty if a FT employee enrolls in Marketplace coverage and
receives a premium tax credit (aka “subsidy”) for the coverage
under IRC section 4980H(a).
‟A Penalty”
An ALE that fails to offers MEC that is affordable and provides
minimum value to FT employees (and their children) may be
subject to a penalty under IRC section 4980H(b) if a FT
employee receives a subsidy for Marketplace coverage.
‟B Penalty”
An employer may choose to comply (‟play”) with the employer shared
responsibility mandate in order to avoid the possibility of “paying” a
penalty, which can be substantial

 Who is an Applicable Large Employer (ALE)?
– ALE is an employer with 50 or more FT and full-time equivalent
employees (FTEs)
– ALE with 50-99 FT and FTEs that meets certain criteria is exempt from
play or pay penalties for 2015
– ALE determination is made on a controlled group basis and based on
prior calendar year employee count
– Liability for, and the amount of, the excise tax is computed and
assessed separately for each ALE member
– Each ALE member is responsible for its own health coverage reporting
 BUT: ALEs exempt from play or pay (e.g., 50-99 FTEs) in 2015 must still
report 2015 coverage – no delay. And, all self-funded plans providing MEC
have reporting obligations, regardless of number of FTEs

What is affordable coverage?
 Employee’s premium contribution does not exceed
9.5% of income – use IRS safe harbors to define
employee’s “income”
 Applies to employee-only coverage – employer does
not have to contribute towards dependent costs
 NOTE: “cash-in-lieu” for waiving coverage or “flex
credits” may affect affordability if employee can take
amount in cash or apply it to non-health benefits
What is minimum value?
 Plan pays at least 60 percent of total allowable costs
 No more than 40% paid by participants: co-pays,
deductibles, co-insurance
 Must provide substantial coverage for in-patient
hospital services and physician services
SAFE HARBORS FOR
AFFORDABILITY
 9.5% of annual earnings in
W-2 (Box 1) divided by 12
months; or
 If salaried, 9.5% of
employee’s monthly salary.
If hourly, 9.5% of 130 hours
x rate of pay; or
 9.5% of individual federal
poverty level (FPL) ($11,770
in 2015) divided by 12
months = (employee
contribution cannot exceed
$93.18 per month)

‟Penalty A”: ALE does not offer minimum essential coverage
 A non deductible tax penalty may be assessed if the employer does not
offer MEC (generally, any kind of group health coverage that is not
“excepted benefits”) to at least the following percentage of its FT
employees (and their children to age 26)
─ 70% in 2015
─ 95%, or, if greater, 5 FT employees starting in 2016 and later
 Penalty is triggered as soon as one FT employee receives a subsidy for
Marketplace coverage
─ 400% of federal poverty level or lower
 $2,000* annual penalty per FT employee in excess of 30 FT employees
(determined monthly = $167/mo)
─ 2015: transition relief excludes 80 FT employees
*May be indexed for inflation

‟Penalty B”: ALE fails to offer plan that provides minimum value and is
affordable
 Applicable large employers may be subject to non-deductible tax penalty
if employer does not offer minimum value at an affordable price to a FT
employee
 Penalty is triggered as soon as that FT employee receives subsidized
health insurance coverage through the Marketplace
 $3,000* annual penalty ($250/mo) per FT employee receiving a subsidy
for Marketplace coverage due to employer’s failure to offer affordable
minimum value coverage
 Penalty B cannot exceed Penalty A if Penalty A applies
*May be indexed for inflation

Who is a ‟Full-time” employee?
 Full-time employee means an employee who has 30 or more hours of
service per week (130 per month):
– Common law standard; includes all W-2 employees (full-time, part-
time, seasonal, temporary, etc.)
– Includes salary, hourly, per diem, or commission only employees
– Does not include a sole proprietor, a partner in a partnership, or a 2%-
or more S corporation shareholder
– Does not include leased employees who are not common law
employees of the employer that receives the services

What is ‟hours of service”?
 Hours of service include:
─ each hour for which an employee is paid, or entitled to payment, for
the performance of duties for the employer, and
─ each hour an employee is paid, or entitled to payment, on account of a
period of time during which no duties are performed due to vacation,
holiday, illness, incapacity (including disability), layoff, jury duty,
military duty or leave of absence

HEALTH COVERAGE REPORTING

What is the purpose?
 Employer reporting of health plan and coverage information provides the
Internal Revenue Service (IRS) with the information necessary to
administer and regulate various ACA provisions:
─ Individual Shared Responsibility rules – individuals must have minimum
essential coverage (“MEC”) or face potential tax penalties
─ Individual eligibility for a premium tax credit/subsidy for coverage
through a public Marketplace
─ Employer Shared Responsibility rules – ALEs must offer qualifying
health coverage to full-time employees or face potential tax penalties
 First required for 2015 calendar year information (reports due in early
2016)

The ACA added two new Internal Revenue Code (“IRC” or “Code”) sections:
Code Sections 6055 and 6056
 Code Section 6055
─ Provides IRS information about individuals enrolled in MEC. Also
requires coverage providers to provide individuals with statements
about the MEC
─ Most providers of health coverage (insurers, self-funded employers) are
required to do this reporting
– Form 1095-B is used for 6055 reporting. Self-funded employers that use
Form 1095-C may report the coverage information in Part III instead of
using Form 1095-B

 Code Section 6056
─ Applicable large employers (ALEs) are subject to the ACA’s employer
shared responsibility rules (“play or pay”), and may face a tax penalty if
qualifying coverage is not offered to full-time employees (as defined
under ACA)
o Section 6056 provides information to IRS about the coverage offer
made by ALEs to verify compliance and to assist with enforcement of
play or pay. Also requires ALEs to provide individuals with statements
about the coverage offered by the employer
─ Form 1094-C (transmittal) and Form 1095-C (return/reporting form) are
used for 6056 reporting

How & when to furnish statements to individuals
 Furnish copy of the 1095-C (or 1095-B or a ‟substitute statement”, if
used) to the ‟Responsible Individual” identified on the form by January 31
of the following year
– In 2016, statements due to employees February 1 (January 31 is a
Sunday)
 Statements must be furnished on paper by mail or electronically under
certain conditions
─ If mailed, send to the recipient’s last known address. Can be mailed
with W-2s
– A statement may be electronically provided if individual affirmatively
consents to such disclosure in a manner that demonstrates ability to
access the electronic statement after receipt of a specific disclosure and
other conditions are followed

How & when to file forms with IRS
 The returns must be filed with the IRS on or before February 28 (March 31
if filed electronically) of the year following the reporting year
─ In 2016, deadline is February 29 because February 28 is a Sunday
 If an employer is required to file 250 or more Forms 1095-B, or 250 or
more Forms 1095-C during a calendar year, returns must be filed
electronically
─ Can request waiver by submitting IRS Form 8508, Request for Waiver From
Filing Information Returns Electronically, at least 45 days before the due date of
the returns
 Must use new IRS e-filing system - Affordable Care Act Information Return
system (“AIR”)
 Details on AIR program website (See “Additional Resources”)

Potential penalties for reporting failures
 Failure to file information return with IRS: $250 per return, $3,000,000
maximum per calendar year
 Failure to provide correct employee statement: $250 for each statement,
$3,000,000 maximum per calendar year. Increased penalties for
intentional disregard of the requirement to provide an employee
statement
 Short-term relief for 2015: IRS states no penalties for 2015 returns and
statements filed and furnished in 2016 if can show good faith efforts to
comply with the reporting requirements (specifically, regarding incorrect
or incomplete information on return or employee statement)
 No relief is provided for reporting entities that cannot show a good faith
effort to comply with the reporting requirements or that fail to timely file
an information return or furnish a statement to individuals

Extensions of Time
Filing with IRS
 Get automatic 30-day extension by submitting IRS Form 8809 on or before
the due date for filing with the IRS
 After automatic extension, an additional 30-day extension possible under
certain hardship conditions
Providing to individuals
 For a 30-day extension, send letter to IRS
̶ See instructions for 2015 Forms 1094-C/1095-C for more information
̶ Request must be postmarked by date on which statements are due to
individuals
© Copyright Trucker Huss, APC | One Embarcadero Center, 12th Floor, San Francisco, California 94111
Telephone: 415-788-3111 | Facsimile: 415-421-2017
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FORMS 1094-C & 1095-C

FORMS 1094-C & 1095-C
 IRS Form 1094-C
─ Used to report employer summary information to the IRS
─ Think of it as a cover sheet for the individual employee forms
 IRS Form 1095-C
– Used to report employee-specific information
– In general, one is required for:
o each full-time employee; and
o each covered employee under a self-funded plan
o can use to report non-employee coverage (or Form 1095-B)
 Both forms are filed with the IRS and a copy of Form 1095 is provided to
each full-time employee and/or covered primary enrollee
 Final 2015 forms and instructions issued September 16, 2015

FORM 1094-C
Form 1094-C (“Transmittal of Employer-Provided Health Insurance Offer
and Coverage Information Returns”)
 1094-C is used to transmit Forms 1095-C
 An ALE member must designate one of its Forms 1094-C as the
“Authoritative Transmittal” to report aggregate employer-level data for
all FT employees
 An ALE member may file Forms 1095-C all at once or in batches
 If ALE member files Forms 1095-C in batches:
─ One 1094-C transmittal is the “Authoritative Transmittal” with
aggregate data for the ALE member
─ The other Forms 1094-C only summarize the Forms 1095-C filed with
them

FORMS 1094-C
 Form 1094-C—Data required
─ ALE member’s contact information and EIN
─ Number of 1095-C statements attached
─ Authoritative transmittal information
o Number of 1095-Cs issued by the ALE member;
o Total employees by month; FT employees by month
o Whether MEC was offered (or deemed to be offered) to required
percentage of full-time employees (and their dependents)
o Eligibility for qualifying offer or qualifying offer transition relief
o Eligibility for “50-99” or deduction of first 80 employees for 2015
o Information about ALE members that are part of aggregated ALE
group

FORM 1094-C: THE TRANSMITTAL FORM

FORM 1095-C
Form 1095-C (“Employer-Provided Health Insurance Offer and Coverage”)
 Reports employee-specific information to IRS
– Copy is provided to each full-time employee and any other enrollees
– In general, one Form 1095-C per employer is required for each full-time
employee or other enrollee
 All ALE members complete Parts I and II of Form 1095-C to report
information about a full-time employee and coverage offered (or not
offered) and type of coverage offered to full-time employees and
dependents
 ALE members with self-funded plans generally complete Part III of Form
1095-C to report covered individuals. (Insurers report this information for
insured plans, separately on Form 1095-B.)

FORM 1095-C
Form 1095-C—Data Required
 Identifying information for ALE member
 Employee name, address and SSN
 Employee FT status
 Employer offer of coverage by month
 Whether qualifying offer (MEC, MV and affordable; whether offered to
spouse and dependents)
 Amount of lowest-cost employee-only MV coverage offered
 If a self-funded plan provides coverage, names of covered individuals
(enrolled family members) name and SSN. Use DOB if cannot obtain SSN
after “reasonable efforts”

FORM 1095-C

OVERVIEW OF HEALTH COVERAGE REPORTING
Type of Reporting Affected Employers Required Information Form
Code 6056 – Applicable Large
Employer (ALE) reporting
ALEs (at least 50 FTEs)
 Insured Plan or No Plan:
ALE member files Form 1095-
C, Parts I and Parts II (and not
Part III). Insurer, if any, files
Form 1095-B
 Self-funded Plan:
ALE member files Form 1095-
C, Parts I, II and III
Terms and conditions of health
plan coverage offered to FT
employees (helps the IRS
administer the ACA’s shared
responsibility penalty for large
employers)
 To IRS:
Form 1094-C (transmittal)
and 1095-C due 2/28 (3/31
if filed electronically)
 To responsible individual:
Informational statements
(e.g., Form 1095-C) due 1/31
 See “Additional Resources”
at end of presentation for
links to online forms.
Code 6055 – Reporting of health
coverage by providers of
minimum essential coverage
 Small employers with self-
funded health plans
 Multi-employer plan sponsors
 Health insurers
 Note: ALEs that sponsor self-
funded plans are also
responsible for 6055
reporting. However, this
reporting usually is done in
Part III of the Form 1095-C.
Information on each individual
provided with coverage (helps
the IRS administer the ACA’s
individual mandate)
 To IRS:
Form 1094-B (transmittal)
and 1095-B due 2/28 (3/31
if filed electronically)
 To responsible individual:
Informational statements
(e.g., Form 1095-B) due 1/31
 See “Additional Resources”
at end of presentation for
links to online forms.

CADILLAC TAX

CADILLAC TAX
 40% nondeductible tax on high-cost health coverage starting in calendar
year 2018
─ Generally applies to major medical coverage, HSAs, HRAs, Health FSAs, and on-
site clinics; does not appear to apply to “excepted benefits,” e.g. stand-alone
dental and vision plans and most EAPs
─ Applies to retiree coverage, multi employer plans, governmental plans that
primarily cover civilian employees
 Applies to costs in excess of $10,200 for self-only coverage, $27,500 for
other than self, employee per year, calculated on a monthly basis
– Higher cost thresholds for certain high risk populations
– Limits include both employee- and employer-paid portions of the cost
 Applies to total cost of the plan (i.e., both the employer and employee
contributions)
 Includes sum of all applicable coverage for an employee

CADILLAC TAX
 All employers are subject to the tax
─ No small-employer exception
─ No church or government plan exception
 Tax assessed against “coverage provider”
– Insured plan – insurer pays
– HSA or Archer MSA – contributing employer pays
– Self-insured plan (e.g., medical, HRAs, health FSAs) – “Person that
administers the plan benefits” pays
 Current guidance indicates excise tax calculation will be determined in a
way that is similar to rules for determining COBRA premiums

CADILLAC TAX
 Regulations not yet issued
 IRS released Notices 2015-16 and 2015-52 to “initiate and inform” the
public
 Legislation, lobbying, change in administration in 2016 may impact the
scope of the tax

CADILLAC TAX
Sample strategies to reduce cost of coverage
 Change benefits – but don’t trigger “play or pay rules”
 Increase defined contributions
 Add more consumer-driven strategies
 Increase offerings of after-tax, voluntary and excepted benefits
 Restrict employer contributions or salary reduction to account-based
plans
 Exclude spousal coverage to reduce cost of family coverage
 Consider private exchange to encourage employees to move from legacy
high-cost health plans, provide new options to manage health care

NEXT STEPS FOR 2016
…AND BEYOND

NEXT STEPS FOR 2016 AND BEYOND
 Benefit limits, changes:
– Update benefit offerings and corresponding plan documents/communications
to comply with 2016 plan limits (i.e., HDHPs, HSAs, OOP maximums)
– Communicate new HSA eligibility provisions for employees receiving health
benefits from the VA due to a service-connected disability
– Amend plan documents/communications to include same-sex spouses as
eligible dependents if required/desired
 W-2s: Employers that filed 250 or more W-2s in 2014:
– Report value of group health coverage on employee W-2s for the 2015 calendar
year by January 31, 2016
 Fees: Employers sponsoring self-funded group health plans:
– Pay applicable PCORI fees for 2015 by July 31, 2016
– Pay applicable TRP fee for the 2014 calendar year by November 16, 2015.
Report 2015 enrollment count and schedule 2016 payments by November 16,
2015

NEXT STEPS FOR 2016 AND BEYOND (CONT.)
 Play or Pay: Employers with 50 or more FTEs subject to transition relief
criteria:
– Offer minimum value, affordable coverage to full-time employees and their
children to avoid potential tax penalties
 Forms 1094/1095 reporting: Employers with 50 or more FTEs
– Coordinate with benefits administration systems, payroll and/or tax preparers
assisting with reporting
– Continue planning and testing of forms preparation process
– If filing electronically in-house, prepare for AIR system filing
– Finalize decisions about how to distribute Form 1095 to covered individuals
– Consider extensions and waivers, deadlines
– Continue tracking data during 2016 to complete IRS health coverage reporting
in 2017
 Cadillac Tax: All employers starting in 2018
─ Watch for additional guidance and regulations from IRS, legislative activity
─ Consider strategies for reducing costs

Q & A
THANK YOU!

ADDITIONAL RESOURCES

EPIC INFORMATION/RESOURCES
 EPIC webinar, ‟ACA Health Coverage Reporting for Employers – Final IRS 2015 Forms &
Instructions” (Oct. 2015): https://vimeo.com/142913298
 EPIC webinar, “Cruising Toward the Cadillac Tax” (Sept. 2015): https://vimeo.com/140331225
 EPIC Compliance Alert, “Final Forms and Instructions Issued for 2015” (September 2015):
http://epicbrokerscom.c.presscdn.com/wp-
content/uploads/2015/05/ComplianceAlert_2015FinalFormsInstructions_0930115_FINAL.pdf
 EPIC Compliance Alert, “Airing Now: The ACA Health Coverage Reporting E-Filing System”
(August 2015):
http://cdn.sparkart.net/edgewoodins/content/pdfs/Alert_ACAPlayorPayMeasurementMethod
sIDFTEmployees_01302015_FinalFinalmms.pdf
 EPIC Compliance Alert, “ACA Play or Pay: Measurement Methods for Identifying Full-Time
Employees” (January 2015) available at
http://cdn.sparkart.net/edgewoodins/content/pdfs/Alert_ACAPlayorPayMeasurementMethod
sIDFTEmployees_01302015_FinalFinalmms.pdf
 EPIC webinar, “Full-Time Employees and the ACA Employer Shared Responsibility Rules” (July
2014): http://vimeo.com/103759499
 ACA Compliance Matters newsletters and other webinars posted on the EPIC Knowledge
Center website: http://www.epicbrokers.com/employee-benefits

IRS FORMS/RESOURCES
 Final instructions for Forms 1094-C and 1095-C (2015):
http://www.irs.gov/pub/irs-pdf/i109495c.pdf
 Final 2015 Form 1094-C: http://www.irs.gov/pub/irs-pdf/f1094c.pdf
 Final 2015 Form 1095-C: http://www.irs.gov/pub/irs-pdf/f1095c.pdf
 IRS Form 8809 (Application for Extension of Time to File Returns):
https://www.irs.gov/pub/irs-pdf/f8809.pdf
 IRS Form 8508 (Request for waiver From Filing Information Returns Electronically):
https://www.irs.gov/pub/irs-pdf/f8508.pdf
 AIR program:
– http://www.irs.gov/for-Tax-Pros/Software-Developers/Information-
Returns/Affordable-Care-Act-Information-Return-AIR-Program
– http://www.irs.gov/for-Tax-Pros/Software-Developers/Information-
Returns/Affordable-Care-Act-Information-Returns-AIR-Program-Did-You-
Know%3F

EPIC is an insurance brokerage and benefits consulting firm and does not provide tax
or legal advice to clients. Therefore it is important to consult legal counsel regarding
this information to determine how it affects your company and what the company
needs to do to comply.

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